Framing Platinum Coin Seigniorage: Part One, Basics

How many times have you heard that the Government can only spend money after it raises revenue by either taxing or borrowing? Nearly every time someone talks or writes about the US’s public deficit/debt problem? How come nobody asks why, since Congress has the unlimited authority to create coins and currency, it doesn’t just create money when it deficit spends? The short answer is that Congress in 1913, constrained the Executive Branch from creating currency or bank reserves, delegated its power to do that to the Federal Reserve System, and never looked back when we went off the gold standard in 1971, even though this removed the danger of money-creation outrunning gold reserves, and also created a new monetary system based on fiat currency.

How It Works

But coins, it turns out are different from currency and bank reserves. They’re the province of the Executive. And Congress provided the authority, in legislation passed in 1996, for the US Mint to create one oz. platinum bullion or proof platinum coins with arbitrary fiat face value, having no relationship to the market value of the platinum used in the coins. These coins are legal tender. When the Mint deposits them in its Public Enterprise Fund (PEF) account, the Fed must credit it with the face value of these coins. The difference between the Mint’s costs in producing the coins, and the reserves provided by the Fed is the US Mint’s “coin seigniorage” or profit from the transaction.

The US code also provides for the Treasury to periodically “sweep” the Mint’s account at the Fed for profits. These then go into the Treasury General Account (TGA), the spending account of the Treasury, narrowing or eliminating the revenue gap between spending and tax revenues. So, for example, say the Secretary of the Treasury ordered the Director of the Mint to create a $60 Trillion (face value) coin; and deposit it in the PEF account at The NY Federal Reserve Bank. The Fed would credit the PEF with $60 T in reserves, and the Treasury would then “sweep” the seigniorage, nearly $60 T, into its spending account.

Benefits

Platinum coins with huge face values such as $60 T, can produce seigniorage closing the revenue gap and technically end deficit spending, while still retaining the gap between tax revenues and spending that can add to aggregate demand and produce full employment. Platinum Coin Seigniorage (PCS) is also a way for the Executive to end debt ceiling crises, since the profits could be used to repay debt instruments when they fall due, without the need to issue any more debt.

If all debt instruments are re-paid by using PCS, then, eventually the US would have no debt subject to the limit, or presence in the bond market, and would pay no interest to bond holders. No one would worry about the public debt, or use its size to justify blocking legislation that fulfills public purpose and promotes the general welfare.

So, PCS-based elimination of debt can end the whole austerity mind set that provides our current budgetary process with its constraining conservative cast, focused on narrow monetary cost considerations, rather than on a broader progressive framework that weighs the real costs and benefits of proposed fiscal activities of the Federal Government. Congress and the Executive would then evaluate the substance of legislative proposals based on their likely direct impacts and side effects on the lives of Americans, rather than their impact on Federal deficits and surpluses. Then the issues will be about what people need, and what improvements we can make by working together through the Federal Government. That would be the fulcrum of a new, game-changing politics, not debt, deficits, and debt-to-GDP ratios.

Why we need to get it done right now!

It must be done now! If it doesn’t, then people who are against the use of PCS will have time to organize against it and get it repealed by the Congress. Now that the PCS capability is widely known, the FIRE Sector will be gunning for it with all the financial, political and propaganda power it can bring to bear. It will do that because using PCS, especially the $30 T or greater coin, High Value Platinum Coin Seigniorage (HVPCS) I propose, strikes at the domination of the financial and political systems by Wall Street and the big banks. Cullen Roche explains why:

The most interesting thing about the coin idea is that the biggest threat of the coin was to the existence of private banking. I am actually surprised that a major bank hasn’t come out very publicly stating that the coin was ridiculous. Why? Because the coin exposes a potentially enormous change in the way the US monetary system functions. Instead of having a money system that is designed almost entirely around private banks (who issue most of the money) the coin threatened to expose the reality that government could self finance if it wanted to. In other words, the government could become the permanent primary issuer of money (as opposed to choosing to use private bank money).

So the Fed’s role is of particular interest here. And we must again ask ourselves. What is the Fed? Is it a public entity or private entity? It’s a bit of both. The Fed is a strange sort of hybrid public/private entity. But the coin decision has to make one wonder where they stand on this issue and whether the Fed has imposed its will on a potentially important debate. Is this merely a case of the Fed being apolitical and independent? Or is this a case of the Fed siding with its true master – the private banking oligopoly? I don’t know, but one thing we know for sure is that the Fed is not merely serving public purpose at all times. After all, its existence as a support feature for an oligopoly that serves private purpose (banks are slaves to their owners) renders the Fed compromised on public purpose to some degree.

So, HVPCS threatens the banks’ domination of the Fed, and also their role in money creation, and with it some of their income. The more time that passes without using HVPCS, the more likely it is that the Executive Branch will lose this capability to Wall Street’s persistent political efforts at repeal, and become the actual, rather than only the pretended (kabuki) prisoner of debt instruments and austerity once again.

Already, some bloggers in the business press who want to use the TDC to avoid the debt ceiling have proposed and expressed support for the idea that the capability to use PCS could be repealed in a swap for repeal of the debt ceiling legislation. This is a very unequal swap, because the power to use PCS, along with the willingness to use it, already makes the debt limit a dead letter.

The only swap that makes any sense is repeal for legislation giving Treasury the same right as the Fed has now, to create money out of thin air, but only for the purpose of repaying debt subject to the limit and covering deficit spending appropriated by the Congress; because this, and only this, is the equivalent of the PCS power. The only thing that would be more preferable than either of those things is to end the “independent,” really big bank and Wall Street dominated, Fed, and make it accountable by placing it under the direct authority of the Executive Branch and the Secretary of the Treasury with the Fed’s current capabilities to create money intact.

Progressives need to fight for retaining the Executive’s capability to use PCS, because that is the quickest road to ending austerity politics and preparing the way for Modern Money Theory-based policies to deliver sustainable economic prosperity, full employment, low inflation, and fiscal policy devoted to the public purpose. Removal of the capability would require that austerity politics be ended through change in the Congress. That sort of change, however, is years down the road, whereas the President can make HVPCS happen right now.

(Author’s Note: h/t to Jack Foster for proposing a framing document for HVPCS. This is it; but divided into 6 parts for blogging convenience)

Depends on how you define “deficit,” or more precisely, how Congress defines it. I said “technically” because I was addressing the Total Revenue – Federal Spending gap; which PCS will close. Of course, if by “deficit” we mean Tax Revenue – Federal Spending; then using seigniorage doesn’t reduce the deficit; which is good because, of course, we need to run larger deficits than we have now to sustain the economy.

“The most interesting thing about the coin idea is that the biggest threat of the coin was to the existence of private banking. I am actually surprised that a major bank hasn’t come out very publicly stating that the coin was ridiculous. Why? ”

Just because there is no support in the mainstream (politics or media or the public) for it, mostly because none of them understand the implications of it. The MSM has giggled and dismissed it. Most of the public probably didn’t even notice that, and are not aware of it at all. The banksters don’t need to say anything.

Even the notion of urgency is moot without a President willing to do it, and he is not. If he were, and didn’t do it right away, he could still veto the repeal bill, or issue the coin before signing it. If the President’ won’t issue the coin, it matters not whether he doesn’t issue it quickly or slowly.

Before the President too PCS off the table, support was building pretty fast and there was enough notice of it to have precipitated much criticism in posts and articles. So, I think it is surprising that during that period no bank decided to express oppostion.

Of course, in urging that it needs to be done now; I’m calling for people to ignore the President’s effort to kill it, and hope that circumstances will combine with external pressure to get him to chance it. That’s why I’m doing this document.

My only concern with your coin is that the people don’t believe it’s possible to just print a trillion dollar coin that has real value and if the people lose faith in the money, what then?? Isn’t there a potential risk here? After all fiat money is based in faith.

If you want general support for MMT you are going to have to educate the public. The public is steeped in old stories about where money comes from etc. Many understand that the FED prints money out of thin air but they don’t understand where the rest of our currency comes from. You’re starting from the top down. OK, good, but I suggest you put energy into the bottom. The people need a place to hook into this complex topic. Where does this arcane topic hit their lives? Foreclosure? Overwhelming debt?

How about FICA taxes? These affect almost everyone, at least everyone on salary or self-employed. With HVPCS, the SS Trust Fund could be augmented while FICA taxes could be reduced (resume the holiday). A student loan Jubilee could also be implemented with seigniorage, as could a mortgage debt reduction or Jubilee. These are some of the places where the rubber hits the road.

Just an observation from my seat in the back section of the stadium. From a political probability perspective, I would rate the chances of the HVPCS pretty low. But the chances of a debt jubilee any time soon are non existent. The teeming millions who pay their mortgages and student loans and those who paid college tuitions without loans, would have none of it. That’s not to say they are not good ideas, but they are an awful tough sell.
That said, Joe is doing a phenomenal job bringing this issue to clarity.

Hey Chew, you are right about opposition from those who never had, have paid, or are paying their student loans or mortgages. Someone suggested just giving a grant to everyone, a rebate for those who have paid, a jubilee for those still owing, and a gift for those who never owed or never attended post secondary school. Resuming the FICA holiday with a grant to SS Trust Fund would be my first choice. All of the above could be achieved under HVPCS.

Also, the debt people owe to the banks is payable in fiat and that fiat can keep them from losing their homes to the banks. Also, since the banks have created many times more debt than the fiat money supply there is a huge sink for any conceivable amount of money the monetary sovereign might create especially if the banks were forbidden from creating any more credit (more credit would reduce the “space” the monetary sovereign could spend in without price inflation).

Where it affects everyone’s lives is that there would be no need for a federal income tax.

Try this thought experiment:

If you could print money (in other words it was not illegal counterfeiting) would you ever borrow from a bank if you needed a car? No you would simply print the money and pay the car dealer with it. Likewise would you need a source of income? No.

If the government was truly printing our money we would have no government debt. It would just print whatever money it needed to pay for social security, roads, or for an aircraft carrier. But instead it borrows the money from private banks.

Instead of the government printing money out of thin air as the Constitution permitted and like founding fathers Franklin, Jefferson and Madison wanted, the government allows the private bankers to print money out of thin air and we borrow from the banks who are the ones who print money out of thin air.

The trillion dollar coin brought all this out in the open. People could immediately see that if the government could issue a trillion dollar coin and pay off a trillion dollars of debt with it, the whole debt issue is nothing but a banking scam. Sixteen trillion dollar coins would pay off all government debt.

Of course, then the Federal government would not have any real necessity to tax either. Only state and local governments, who do not have the ability under the constitution to create money would have to tax to raise income.

A couple of points are in order here. While the trillion dollar coin issue authorizes the executive branch to mint such a coin, Congress also has the power to do it under Article I Section 8, which authorizes Congress to coin money and declare its value. The legal question here is whether Congress can give this authority to the executive or whether the Constitution required Congress to retain this power. This could go both ways if presented to the Supreme Court.

But there is another point to consider as well. Under the legal tender cases (a/k/a the greenback cases) the Supreme Court held that the term “coin money” also meant to print paper money and the Congress had the right to print paper money not only because printing paper money was equivalent to coining money but because printing money was also part of Congress’ war powers under Article I, Section 8.

So the Supreme court has clearly said that Congress has the right to print money out of thin air and whether you do it by coin or paper makes no difference.

The ultimate issue is who gets to print money out of thin air: “We the people” or the banks. In 1913 Congress ceded that ability to the banks with the Federal Reserve Act. We desperately need the government to take it back.

“The legal question here is whether Congress can give this authority to the executive…”
Congress has already delegated this authority to the Federal Reserve, which is more a part of the executive than it is a part of either the judicial or legislative branches, although the FR likes to claim independence. Beowulf and Joe Firestone have both looked at this relationship and concluded that the FR would probably loose a challenge to the authority of the executive for several reasons. First, it would probably not have standing before the courts, second, the relationship spelled out in the federal codes placers the Secretary of the Treasury over the FR board and Chairman in cases of conflict and third, the Supreme Court would likely rule in favor of the Unified Executive concept which would place the FR directly in the executive branch under the Treasury. Also, the Treasury has been given explicit power to mint coins and the platinum coin seigniorage act plainly states that the Secretary of the Treasury has the discretion to determine the amount and number of platinum coins minted.
Congress could of course revoke the authority it has given, which is why Joe believes the President should act before revocation can happen. A Presidential veto could make revocation difficult, but not impossible.

As far as I know there are no cases on the issue of delegation to the executive. Just because Congress delegated this authority to the Federal Reserve in 1913 doesn’t mean that if the act were contested today, the Supreme Court would hold that Congress had the right to do it a hundred years ago. The question of constitutionality is not decided until a court rules on it. Many statutes have been in existence for years and years and followed and then someone decided to contest the constitutionality of what the legislative branch did and low and behold the court held it unconstitutional.

Hey Joe, I love the national equity you suggest when invoking HVPCS as “The seigniorage from a $60 T platinum coin would serve as a potent symbol”. One would think all the blood,treasure and progress have a value, at least as infinite as 60t might suggest. The country has been waiting on payday for all of the effort this union represents.

There are Euro coins, but I don’t know where they come from. If the countries in the Euro have retained their coin seignorage rights, then perhaps they could do it. If they’re issued only by the ECB, then no. The ECB can issue as many Euros as it wishes, in paper or coins or bits in their computer.

China could do it, maybe, I’m not familiar with their internal monetary mechanisms. They don’t seem to have any qualms, currently, about spending enough to keep their economy growing at a brisk pace. Brazil, likewise, is monetarily sovereign and can spend as much as it wishes, whether or not coin seignorage or government bonds are involved. But, again, they may not have the same internal setup that we have in the US. The TDC idea is the result of our laws regarding deficit spending and the debt ceiling, the separation of financial powers between the Congress and the Executive branch, and a peculiarly written clause in one coinage statute. No other country has a debt ceiling law, so the idea is probably not relevant for them.

The Eurozone as a whole, and the nations you mentioned have no need for HVPCS, since the issues for them are whether their legislators, or in the case of China, their rulers, will allow their central banks to directly fund deficit spending by their Treasuries. the same would be true here, except for the fact that Congress has already legislated the ability for Treasury to produce coins with face values specified by Treasury fiat.

Hey Admin,
Hope you are fine and doing well. I am Jack from Oak view law group i.e Ovlg.Com and I am willing to write guest post for your blog http://neweconomicperspectives.org/ May I know how many word count are allowed?
If you have any more financial blogs, then please send the list.

“The short answer is that Congress in 1913, constrained the Executive Branch from creating currency or bank reserves, delegated its power to do that to the Federal Reserve System”

Check your facts. The executive government was still allowed to issue US notes after the establishment of the Fed in 1913. Legislation in the 1880s constrained the Treasury from issuing more than ~$300 million in US notes.

Why should the banks be opposed to Platinum Coin Seigniorage? With no limits on the usury they can charge and no limits on the amount of debt they can issue they can easily keep ahead of any price inflation the monetary sovereign might cause.

Banks are not limited by reserves since they can always borrow them from other banks or the Fed if necessary. Aside from miniscule capital requirements (that the banks are always trying to reduce even more), the banks are only limited by the number of “credit-worthy” borrowers who are willing to borrow. But during an inflationary boom, many more people are willing to borrow and the banks are much more willing to consider them “credit-worthy” for the right interest rate.

Yeah, that’s what I figured you meant after asking the question. But wouldn’t you expect the credit demand to fall if and when significant sums were regularly spent out of PCS profits? Plus, you are hacking at the bond yields, too. Do the banks not lose anything from that?

But wouldn’t you expect the credit demand to fall if and when significant sums were regularly spent out of PCS profits? Nihat

At the first whiff of price or asset inflation, I would expect the banks (via speculating borrowers) to pour credit into the economy and create a self-sustaining (till the inevitable bust, of course) demand for even more credit.

Plus, you are hacking at the bond yields, too. Nihat

But they are pitifully low already. The banks would much prefer another boom is my bet.

You may be right re: what the banks would prefer. But, they’d prefer it any day. Afaics, the PCS’s effect is likely to make it harder for them to get it rather than easier, at least in the medium to long term. Eroding dependence of the govt on bank money will eventually be followed by similar erosion in private credit demand, imo.

Thanks Joe. Every time someone brings up the “unsustainable” national debt and the US “borrowing” I ask them these questions and that shuts them up and they walk away all confused and angry at themselves.
We all can agree that US Federal taxes can only be paid in US dollars, so what comes first, Taxes or Dollars? Where does the US dollar come from before we can pay these taxes? If your answer is government borrowing, then who are we borrowing it from and how did this entity get these dollars in the first place?
Can you borrow something that doesn’t yet exist?﻿ Finally if we are really borrowing from someone, shouldn’t the lender be the one setting the interest rates and not the borrower? How come the US govt can set the interest rate at which it wants to borrow and how come each time it borrows more the rates keep going down?

“The point of HVPCS is to enable us to live within our means, not way below them (cf. high unemployment and underemployment); it is not to go out and buy China or Brazil.”

Or put another way the point is to show that a sovereign currency issuing central government doesn’t have to live within the means of a “credit card balance sheet” but within their national resources particularly labor.

“We all can agree that US Federal taxes can only be paid in US dollars, so what comes first, Taxes or Dollars? Where does the US dollar come from before we can pay these taxes? If your answer is government borrowing, then who are we borrowing it from and how did this entity get these dollars in the first place? Can you borrow something that doesn’t yet exist?”

And you might ask what the point is of creating money in the first place. To ask if they think it helps labor to be instructed to use resources to produce goods and services and if so isn’t money then just a form of “financialised instruction.” Finally to ask if it doesn’t make sense for a nation to make the best use of the resources available, particularly labor, by issuing” instructions in the shape of money” and especially government in a recession to get the economy going again when the private banks are reluctant to create those “instructions” in the shape of bank loans

In the end, this is an attempt to circumvent the will of Congress. Now, you may disagree, since Congress created the platinum coin law. But that’s really beside the point. Certainly the intent of the platinum coin law was not to provide for paying down the national debt.

Rather than push for the use of the platinum coin, one should use the understanding exposed by the possibility of the platinum coin to have Congress draft some laws that deal the the modern monetary system as adults. I know that’s asking a lot, but you have to try, don’t you?

The probability of the President using HVPCS may be extremely small, but the probability of getting this Congress to draft some laws dealing with MMT as adults is zero. I have yet to hear a single Senator and so far only one Representative even talk about monetary sovereignty and the possibility of using fiat money to fund public services. Perhaps in some ideal future world this might happen, but for now the only hope is for the President to be forced by circumstances to reverse his opposition, which he has a good track record of doing with regard to other issues.

But why does it matter? Do you think that if the president gave the Fed a coin and changed some numbers that the Congress is going to behave any differently? The goal isn’t to change the number we call the deficit. The goal, I would think, is to have the government function in the best interest of the general population instead of the rich and special interests. I can’t quite see the coin doing that.

An economy is in the end about dividing up real resources and determining who is going to work and how much. I don’t see deficit reduction — through the coin or any other method — changing our behavior in this regard.

I think Joe has given a plausible description of the changes in attitude that HVPCS could produce. At the very least it would silence the “government is running out of money” crowd and show the general public that the government can create fiat money in any amount needed to fund the public purpose. What Congress critters do with this information is anybody’s guess, but at that point there will be a fire to hold their feet to.

Who really knows what the will of Congress was? And that would be the constitutional question for the Supreme Court. Congress clearly left the determination of the value of the coin up to the executive branch. Was this a mistake? Would Congress even sue in the federal courts to take the issue up if a bold executive took the initiative to coin a trillion dollar coin and it proved to be highly successful?

The Supreme Court was faced with a similar issue of success in the legal tender cases after Lincoln issued greenbacks that helped him win the war. Nothing gets the Supreme Court’s attention like success. Plus there are the greenback cases as precedent for the executive taking the lead in a case of national emergency.

There is also the question of standing for Congress. A few or even a significant number of Congresspoeple almost certainly would not have standing before the Supreme Court in a dispute with the Executive Branch. The precedent for this is a suit by two Senators related to the War Powers Act in which the Court said the Senators had no standing. The Constitution sets out mechanisms for establishing authority between branches, and the SC is reluctant to get involved in such a dispute. Legislation, veto, and override is the relevant mechanism.

It probably would not be Congress suing but someone claiming that Congress did not have the right to do what they did. But you are right, standing would be a real problem for whoever was plaintiff. Maybe the Federal Reserve banks or a member bank would have standing.

The more I think about I am sure you are right. Congress would not have standing. It would take some entity like the Federal Reserve or one of the member banks. Don’t know if the Federal Reserve Board of Governors would have standing to sue but it might also. Interesting issues.

David, it might be that the FR, or one or more of the member banks, would have standing, but what would be the issue that they could bring before the courts? They certainly wouldn’t claim that Congress violated the Constitution by delegating it’s authority to issue currency since they are the agency that has benefited from that delegation for 100 years. The only issue I see the FR bringing is a claim that the coin(s) are not legal tender. If they are struck by the US Mint, have the proper insignia (what ever is required by law), and are delivered for deposit by the Treasury, I don’t see how the FR can reject them as it is the deposit agency for the Treasury. The FR already has accepted billions of dollars in uncirculated coins that the Mint has struck and no commercial banks are calling for, so no demand is not a viable issue. Am I missing some issue here?

I agree. How do they show harm? That would be a hoot. They would essentially be saying we don’t want your stinking money. Like I said in section 2 on the legal question, it would cause a serious problem for the Fed not to accept valid legal tender.

Somewhere on one of these threads I talked about the Federal Reserve Board of Governors being and “independent agency,” which is an oxymoron, if there ever was one. Technically it is not, as I understand it, under the executive, legislative or judicial branches of government, and thus this agency has no real principal. About the only control that I can see that the executive and Congress exerts over it, is the ability to appoint the members of board and to fire the members, and as I understand it, the board members are chosen from approved lists made by the Federal Reserve Banks. But that is hardly the kind of control a principal normally exercises over its agent.

So this makes the delegation issue even worse for them. If Congress can delegate to this “independent agency” over which it has virtually no control, then it would seem to be that Congress could certainly designate to the executive branch where the usual checks and balances apply.

I guess the Fed could argue that it was very harmful to them to lose the monopoly of creating money out of thin air. Certainly with the employment of some fancy economic gobblydegook they could make this argument sound much better.

David, just a couple of things. First, the Fed can’t sue because the law provides that when the Secretary and the Chairman of the Fed disagree on a matter of interpretation, the view of the Secretary shall be controlling. So, if the Chairman tried to sue; it would be a violation of law and he/she could be fired for cause. On the other hand, once the Chairman acknowledges that the view of the Secretary is controlling than the President of the NY Fed can’t very well deny the Treasury’s instruction to credit the coin, since to do so would to contravene BOG policy.

Second, the Fed couldn’t argue that it was losing “the monopoly of creating money out of thin air.” The reason why is that such a monopoly was never delegated by Congress. What was delegated was “the monopoly of creating currency” out of thin air. Currency is not coinage, and authority to coin money was delegated to the Treasury by Congress. Now what the Fed might sue about, if it could get standing, is that by depositing the coin the Treasury was, in effect, commanding the Fed to create electronic credits in return for the coin, and that those credits would be used by Treasury to add huge quantities of money to the money supply, thus compromising the independence of the Fed to set monetary policy, by forcing it to compensate for huge Treasury infusions of high-powered money. This kind of argument, however, can easily be countered by Treasury replying that if the Court ruled that the Treasury could not deposit HVPCS coins and receive credit for it from its sole legal banking agent, the Fed, then, it would be forcing Treasury to use only taxing or borrowing to get the credits needed to deficit spend Congressional appropriations. Treasury could then follow by saying that The Court would be overstepping its authority if it decided this because if Congress had intended that Treasury not use seigniorage revenues for spending purposes it would have clearly limited its use in this way. So, it seems that the Court would be faced with the choice of interfering with the Treasury’s function of getting the credits it needs to spend mandated appropriations, or interfering with the Fed’s independence in the area of monetary policy. Faced with that kind of choice I think the Court would have to fall back on the law’s specification in case of disagreement the interpretation of the Secretary will be controlling.

It would have to do that because 1) the law says that; and 2) the Treasury’s capability to acquire the credits necessary to implement mandated Congressional appropriations is quite a bit more fundamental to the integrity of the Republic than the Fed’s need to conduct monetary policy without interference from the Executive.

I guess when I am being sarcastic, I need to get some kind of icon to paste in. Sorry. Yes it is not an absolute monopoly. Glad to know Joe that the Fed can’t sue either. It would have to be some other entity that could show harm from the Fed being required to take the coin. Don’t know who that could be.

If I recall though, the rumor I heard was that the Fed told Obama it wasn’t going to take the coin. Of course if that is true, Obama didn’t force the issue. I forgot what the Fed’s alleged excuse was as to why they wouldn’t take it.

But I think we all agree that Obama would have been on solid ground printing the trillion dollar coin. It’s a damn shame he didn’t take the opportunity.

I can’t speak for Joe, but I guess I have a hair trigger for objections to HVPCS because so many of them are far more ridiculous than your tongue in cheek jibe, but the commentators are deadly serious (at least I think they are). Sorry to have lumped you in with the nit wits.